Model Policy Name: Privacy
Policy Date: 01/01/2026

Privacy Policy

This privacy and cookies policy (Policy) sets out the basis
on which any information that we collect from you, or that you provide to us,
will be processed by us. Some of this information will be personal data, which
is specifically protected under the Data Protection Act 1998. 

By accessing and browsing our website, you confirm that you
accept and give your consent to the processing of your personal data as
described in this Policy. 

You are advised to read this Policy carefully before using
our website and the services provided through it. 

Information about us 

Freedom Recruitment Capital Ltd (”we”/”us”/”our”) are
committed to protecting and respecting your privacy. This “Privacy Policy” sets
out the basis on which any personal Data (as defined in clause 3 below) we
collect from you, or that you provide to us, will be processed by us. Please
read the following carefully to understand our views and practices regarding
your personal Data and how we will treat it. By visiting our “Website” www.freedomrecruitmentcapital.co.uk
you are accepting and consenting to the terms in this Privacy Policy. For the
purpose of the Data Protection Act 1998 (the Act), the “Data Controller” is Freedom
Recruitment Capital Ltd, company number 14070079. If you have any questions
about this Privacy Policy or our privacy practices, please contact our Data
Protection Officer in the following ways: 

Full name of legal entity: Freedom Recruitment Capital Ltd
Company Number: 14070079
Email address: start@freedomrecruitmentcapital.co.uk
Postal address: 2 Trinity Place, Midland Drive, Sutton Coldfield, West Midlands
B72 1TX

You have the right to make a complaint at any time to the
Information Commissioner’s Office (ICO), the UK supervisory authority for Data
protection issues (www.ico.org.uk). We would, however, appreciate the
chance to deal with your concerns before you approach the ICO so please contact
us in the first instance. 

Terms of Use 

  1. a)
    The content of our Website is protected by trademark, copyright, database
    and other intellectual property rights and you acknowledge that the
    material and content supplied as part of our Website shall remain with us
    or our licensors. You may display the content of the Website on a computer
    screen or mobile phone screen, store such content in electronic form on
    disk (but not any server or other storage device connected to a network)
    or print one copy of such content for your own personal, non-commercial use,
    provided you keep intact all and any copyright and proprietary notices.
    You indemnify us that you will not otherwise copy, scrape, modify,
    reproduce or distribute or use for any purposes any of the materials or
    content on our Website. Any breach of this indemnity will result in court
    proceedings and reporting such instances to the police and other
    authorities.
  2. b)
    We shall not be liable to you under or in connection with this Privacy
    Policy or any collateral contract including, but not limited to, the
    following:
  1. loss
    of revenue;
  2. loss
    of contracts;
  3. loss
    of the use of money;
  4. loss
    of anticipated savings;
  5. loss
    of business;
  6. loss
    of opportunity;
  7. loss
    of goodwill;
  8. loss
    of reputation;
  9. loss
    of, damage to or corruption of Data; or 
  10. any
    indirect or consequential loss, 

 

Data you give to us. We will use this Data

– to carry out our obligations arising from any contracts
entered into between you and us and to provide you with the information,
products and services that you request from us; 

– to provide you with information about other goods and
services we offer that are similar to those that you have enquired about; 

– Where it is necessary for our legitimate interests (or
those of a third party) and your interests and fundamental rights do not
override those interests; 

– Where we need to comply with a legal obligation; 

– to provide you, or permit selected third parties to
provide you, with information about goods or services we feel may interest you.
If you are an existing customer, we will only contact you by electronic means
(e-mail or SMS) with information about goods and services similar to those
which were the subject of a previous enquiry. Where you want us to use your
Data in this way, or to pass your details on to third parties for marketing
purposes, please tick the relevant box situated on the form on which we collect
your Data. Where we permit selected third parties to use your Data, we (or
they) will contact you by electronic means, only if you have consented to
this; 

– to notify you about changes to our service and products;
and 

– to ensure that content from our Website is presented in
the most effective manner for you and for your computer or device. 

Data we collect about you 

We will use this Data : 

– to administer our Website and for internal operations,
including troubleshooting, Data analysis, testing, research, statistical and
survey purposes; 

– to improve our Website to ensure that content is presented
in the most effective manner for you and for your computer; 

– to allow you to participate in interactive features of our
service, when you choose to do so; 

– as part of our efforts to keep our Website safe and
secure; 

– to measure or understand the effectiveness of advertising
we serve to you and others, and to deliver relevant advertising to you; 

– to make suggestions and recommendations to you and other
users of our Website about goods or services that may interest you or
them; 

– to prevent misuse of our or third parties intellectual
property, or fraud (including credit card fraud and fraud we think has happened
during a competition or promotion) or other crimes; and 

– to protect the security of our company, employees, our
clients, customers, third parties and/or our/their property as permitted by
law. 

Data we receive from other sources. We will combine
this Data with Data you give to us and Data we collect about you. We will use
this Data and the combined Data for the purposes set out above (depending on
the types of Data we receive). 

Marketing. We strive to provide you with choices
regarding certain personal Data uses, particularly around marketing and
advertising. We may use your Identity, Contact, Technical, Usage and Profile
Data to form a view on what we think you may want or need, or what may be of
interest to you. This is how we decide which products, services and offers may
be relevant for you (we call this marketing). You will receive marketing
communications from us if you have requested information from us or purchased
goods or services from us and you have not opted out of receiving that
marketing. 

Third-party marketing. We will get your express
opt-in consent before we share your personal Data with any third party for
marketing purposes. 

Opting out. You can ask us or third parties to stop
sending you marketing messages at any time. You may stop our marketing by
following the opt-out links on any marketing message sent to you or by
contacting us at any time. Alternatively, you can email us at start@freedomrecruitmentcapital.co.uk
and highlighting your comment in the heading section “unsubscribe”. Where you
opt out of receiving these marketing messages, this will not apply to personal
Data provided to us as a result of a product/service purchase, product/service
experience or other transactions. 

Disclosure of your Data 

  1. a)
    You agree that we have the right to share your personal Data with:

– Any member of our group, which means our subsidiaries, our
ultimate holding company and its subsidiaries, as defined in section 1159 of
the UK Companies Act 2006; 

– Selected third parties including; 

business partners, suppliers and sub-contractors for the
performance of any contract we enter into with them or you; 

advertisers and advertising networks that require the Data
to select and serve relevant adverts to you and others. We do not disclose
Data about identifiable individuals to our advertisers, but we will provide
them with aggregate Data about our users (for example, we may inform them that
500 men aged under 30 have clicked on their advertisement on any given day). We
may also use such aggregate Data to help advertisers reach the kind of audience
they want to target (for example, women in SW1). We may make use of the
personal Data we have collected from you to enable us to comply with our
advertisers’ wishes by displaying their advertisement to that target audience;
and 

analytics and search engine providers that assist us in the
improvement and optimisation of our Website. 

  1. b)
    We will disclose your personal Data to third parties:

– In the event that we sell or buy any business or assets,
in which case we will disclose your personal Data to the prospective seller or
buyer of such business or assets; 

– If Freedom Recruitment Capital Ltd or substantially all of
its assets are acquired by a third party, in which case personal Data held by
it about its customers will be one of the transferred assets; and 

– If we are under a duty to disclose or share your personal
Data in order to comply with any legal obligation, or in order to enforce or
apply our terms of and other agreements; or to protect the rights, property, or
safety of Freedom Recruitment Capital Ltd, our clients, or others. This
includes exchanging information with other companies and organisations for the
purposes of prevention of crime including but not limited to fraud protection,
credit risk reduction and prevention of terrorism. 

– Professional advisers acting as processors or joint
controllers including legal advisers, bankers, auditors, accountants and
insurers based in the UK who provide consultancy, banking, legal, insurance and
accounting services. 

– HM Revenue & Customs, regulators and other authorities
acting as processors or joint controllers based in the UK who require reporting
of processing activities in certain circumstances. 

Where we store your personal data 

– The Data that we collect from you will be stored at, a
destination inside the European Economic Area (”EEA). By submitting your
personal Data, you agree to this transfer, storing or processing. Freedom
Recruitment Capital Ltd will take all steps reasonably necessary to ensure that
your Data is treated securely and in accordance with this Privacy Policy. 

– All Data you provide to us is stored on secure servers
using SSL technology. 

– We will only transfer Your Data to countries that have
been deemed to provide an adequate level of protection for Data by the European
Commission. For further details, see European Commission: Adequacy of the
protection of personal Data in non-EU countries. 

– Where we use certain service providers, we may use
specific contracts approved by the European Commission which give Data the same
protection it has in Europe. For further details, see European Commission:
Model contracts for the transfer of personal Data to third countries.  

– Unfortunately, the transmission of Data via the internet
is not completely secure. Although we will do our best to protect your personal
Data, we cannot guarantee the security of your Data transmitted to our Website;
any transmission is at your own risk. Once we have received your Data, we will
use strict procedures and security features to try to prevent unauthorised
access. 

Your Rights 

You have the following rights in relation to Your
Data: 

  1. Right
    to access Data
     – the right to request known as a “Data Subject
    Request” (i) copies of the Data we hold about you at any time, or (ii)
    that we modify, update or delete such Data. If we provide you with access
    to the Data, we hold about you, we will not charge you for this, unless we
    believe in our sole discretion that your request is “manifestly unfounded
    or excessive”. Where we are legally permitted to do so, we may refuse your
    request. If we refuse your request, we will tell you the reasons why in
    writing (email to suffice);
  2. Right
    to correct Data
    – the right to have your Data rectified if it is
    inaccurate or incomplete;
  3. Right
    to erase Data
    – the right to request that we delete or remove your Data
    from our systems;
  4. Right
    to restrict our use of your Data
     – the right to “block” us from
    using your Data or limit the way in which we can use it;
  5. Right
    to Data transfer
     – the right to request that we move, copy or
    transfer your Data; and
  6. Right
    to object
     – the right to object to our use of your Data including
    where we use it for our legitimate interests.

To make enquiries, exercise any of your rights set out
above, or withdraw your consent to the processing of your Data (where consent
is our legal basis for processing your Data), please contact us via this e-mail
address: start@freedomrecruitmentcapital.co.uk.
 We try to respond to all legitimate requests within one (1) month of
receipt of notice. Occasionally it could take us longer than a month if your
request is particularly complex or you have made a number of requests. In this
case, we will notify you and keep you updated. 

If you are not satisfied with the way we have handled your
Data, you may be able to refer your complaint to the relevant Data protection
authority. For the UK, this is the Information Commissioner’s Office (ICO). The
ICO’s contact details can be found on their website at https://ico.org.uk/. We are registered
under the ICO. 

It is important that the Data we hold about you is accurate
and current. Please keep us informed if your Data changes during the period for
which we hold it. 

How long will you use my personal data for? 

We will only retain your personal Data for as long as
reasonably necessary to fulfil the purposes we collected it for, including for
the purposes of satisfying any legal, regulatory, tax, accounting or reporting
requirements. We may retain your personal Data for a longer period in the event
of a complaint or if we reasonably believe there is a prospect of litigation in
respect to our relationship with you. 

To determine the appropriate retention period for personal
Data, we consider the amount, nature and sensitivity of the personal Data, the
potential risk of harm from unauthorised use or disclosure of your personal
Data, the purposes for which we process your personal Data and whether we can
achieve those purposes through other means, and the applicable legal,
regulatory, tax, accounting or other requirements 

By law we have to keep personal Data about our customers
(including Contact, Identity, Financial and Transaction Data) for six years
after they cease being customers for tax purposes. 

In some circumstances you can ask us to delete your Data,
see Your Rights above, for further information. 

We may anonymise your personal Data (so that it can no
longer be associated with you) for research or statistical purposes, in which
case we may use this Data indefinitely without further notice to you. 

Links to other websites 

Our Website may, from time to time, provide links to other
websites. We have no control over such websites and are not responsible or
liable for the content of these websites. This Privacy Policy does not extend
to your use of such websites. You are advised to read the privacy policy and
terms of use or statement of other websites prior to using them. 

Changes to our Privacy Policy 

Any changes we make to our Privacy Policy in the future will
be posted on this page. Please check back frequently to see any updates or
changes to our Privacy Policy. This Privacy Policy was last updated in January
2026.

Severability 

If any court or competent authority finds that any provision
of this Privacy Policy (or part of any provision) is invalid, illegal or
unenforceable, that provision or part-provision will, to the extent required,
be deemed to be deleted, and the validity and enforceability of the other
provisions of this Privacy Policy will not be affected. 

Partnership 

Nothing herein contained shall give rise to a partnership,
joint venture or a contract of employment between you and us. 

Assignment 

You may not assign, mortgage or otherwise transfer this
Privacy Policy or any rights, duties and obligations hereunder. It is
acknowledged by you that we may use our employees, officers, representatives or
third party consultants to carry out our work within this Privacy Policy. We
may assign the benefit of this Agreement and Data to any firm or company in
which we hereafter acquire a controlling interest or which acquires a
controlling interest in us without prior approval from you. Save that we shall remain
primarily liable hereunder until such time as the prospective assignee enters
into a direct covenant with you to fulfil our obligations hereunder. 

Waiver 

No waiver or affirmation of any breach of or non-compliance
with any term hereof by the parties shall be deemed to be a waiver or
affirmation of any preceding or succeeding breach of or non-compliance with the
same or any other term. 

Third Parties 

Save to the extent expressly set out herein this Privacy
Policy is not intended to nor shall it create any rights, entitlements, claims
or benefits enforceable by any person that is not a party hereto. Accordingly,
save to the extent expressly set out in this 

Privacy Policy, no person shall derive any benefit or have
any right entitlement or claim by virtue of the Contract (Rights of Third
Parties) 1999. 

Jurisdiction 

This Privacy Policy shall be governed by and construed in
accordance with the laws of England and Wales. The parties irrevocably agree
that the English Courts shall have exclusive jurisdiction to settle any dispute
(including non-contractual dispute) arising out of or in connection with this
Privacy Policy. 

Contact 

Questions, comments and requests regarding this Privacy
Policy are welcomed and should be addressed to start@freedomrecruitmentcapital.co.uk